ML20154E625

Forwards Numac Dc Wide Range Monitor Addl Verification Plan Proposed by Ge.Actions Can Be Completed & Results Reported to NRC within 60 Days Following Written Approval of Proposed Plan

ML20154E625
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	09/12/1988
From:	Frisch R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8809190078
Download: ML20154E625 (4)

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@rewrasv5 ABENGEAN'S MISSNE55 Power oeneral Offt<*e: 1945 Weet ParneH Road. Jedtzn, MI 49201 . (817) 788 0550 September 12, 1988 1

Nuclear Regulatory Comission Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIC ROCK POINT PLANT -

POST-IMPLEMENTATION VERIFICATION REVIEW OF NEUTRON HONITORING SOF'1VARE Amendment 91 to the Big Rock Point Operating License dated May 17, 1988, approved Technical Specification c.b u ges associated with the modification to  ;

the out-of-core neutron instrumentation. Included in this amendment was a ,

request to perform an independent, post-implementation Serification review of I the software, as discussed in Section 4.0(2) of the safety evaluation and to -

report d.. results and findings within 120 days.

On August 11, 1988, a meeting was held with the Nuclear Regulatory Commission, General Electric and Consumers Power Company representatives in the Nuclear Regulatory Cor: mission offices to resolve this issue. During the meeting there was a lengthy discussion about software verification and the requirements for an independent reviewer. General Electric's position, which is supported by Consumers Power Company, is that (1) an independent reviewer can be in the some functional organization as the designer as long as he was not specifi- l cally involved in the project design; (2) this is important to assure the l availability of qualified technical reviewers capable of performing this type of review; and (3) the precedent has been recognized and supported by the t Nuclear Regulatory Commission in 10 CFR 50, Appendix B. Regulatory Guide 1.152 and ANSI /IEEE-ANS-7.4.3.2 herein it states:

"The verifying or checking process shall be perforned by individuals or  !

groups other than those who performed the original design, but who may I be from the same organization." (

The Nuclear Regulatory Cor: mission reviewers expressed concerns that (1) they [

vere not certain of the above interpretation of independent reviewer vis-a-vis l Appendix B was correett (2) computer sof tware was dif ferent t han hardware and l needed to have verification done outside the responsible design organization [

OC0988-0118-NLO4 f00 880919o078 DR 800912 '

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Nuciccr Rsgulctory Commission 2

! Palisades Plant f Post-Implementation Verificaticn Review

. September 12, 1988 l

(no common manager); and (3) companies may take "short cuts" and avoid the needed verification rigor if done within the name organization.

In the ensuing discussion General Electric pointed out that it was commer-cially in the best interest of a supplier to assure that software and other design features are rigorously verified by the most qualified people, so that the commercial and safety objectives are aligned.

In mutual understanding of both positions, a compromise was reached wherein the Nuclear Regulatory Commission reviewers agreed to consider an alternate approach proposed by General Electric to accomplish verification and resolve the issue.

The attachment describes the Additional Verification Plan proposed by General Electric. As discussed in the meeting, the actions can be completed and results reported to the Nuclear Regulatory Commission eithin 60 days following written approval of the proposed plan.

Should additional questions or concerns be raised with respect to this Addition-al Verification Plan, they cay be addressed to Consumers Power Company or directly to D W Reigel or C A VonDamm at General Electric in San Jose, California.

d A CC.

Ralpi R Frisch Senior Licensing Analyst CC Administrator, Region III, NRC NRC Resident Inspector - Big Rock Point Plant Attachment OC0988-011E-NI.04 1

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l ATTACHMENT Consumers Power Company Big Rock Point Plant Docket 50-155 1

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l l BIG ROCK POINT l NUMAC DC WIDE RANCE MONITOR

ADDITIONAL VERIFICATION PLAN l

l September 12, 1988 l

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BIG ROCK POINT DC WIDE RANGE MONITOR ADDITIONAL VERIFICATION PLAN i

The NRC review of the Big Rock application for Amendment 91 to the Facility Operating License covering the replacement of existing neutron monitoring equipment with NUMAC DC Wide Range Monitor included a requirement that addition-al independent verification of some elements of the software design was necessarv prior to final acceptance. As a result of several discussions with the NRC including a meeting on August 11, 1988, on another GE NUMAC applica-tion, GE plans to perform additional verifications for the Big Rock DCVRM as described below.

The significant documents / elements to be considered are:

1) The DCWRM Product Performance Specification, including User's Manual (provides the functional requirements)

2) The Functional Software Design Specification (describes the software structure and design)  !

3) The functional software code

4) The module and integration test report (results of design testing, includ-ing detail testing of software paths)

5) The validation test report (results of formal validatioO testing) l Item 1) and 2) have received a comprehensive independent veriffeation and no further verification is planned.

Item 3) received a limited verification review, but in light of the NRC concerns, will be reverified, l

Item 4) was not previously verified, so it will be verified by independent  !

I code review.

1 Item 5) was not previously verified, so it will be verified by independent review. ,

l For these additional verifications every effort will be cade to find a quali-fled organizationally independent verifier. If that is not possible CE will l advise Big Rock Point prior to proceeding with the verification. l 1

The above verifications can be completed within 60 days of notification that completion of the above planned action is satisfactory to close out the issue.

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